New Land Rights Provisions in Batam and IKN: Granting of HGB Now Allowed for Areas of up to 2 Million Square Meters

In 2022, the Minister of Agrarian Affairs and Spatial Planning/Head of the National Land Agency (“ Minister ”) issued Regulation No. 16 of 2022 on the Delegation of Authority for Determinations of Land Rights and Land Registration Activities, as amended by Regulation No. 2 of 2025 (collectively referred to as “ Regulation 16/2022 ”). Broadly speaking, Regulation 16/2022 sets out the Minister’s authority as regards determinations and registrations of land rights, including the Right to Cultivate (Hak Guna Usaha –“ HGU ”), Right to Build (Hak Guna Bangunan –“ HGB ”) and Right of Use (Hak Pakai –“ HP ”).